2d Circuit Case Commentaries

Second Circuit Requires Intent-Focused CAT Analysis of “State of Exception” Detention and Prison Conditions for Suspected Gang Members

Date: Jul 11, 2026

Second Circuit Requires Intent-Focused CAT Analysis of “State of Exception” Detention and Prison Conditions for Suspected Gang Members 1. Introduction Aguilar-Villalobos v. Blanche is a Second...

Indemnification Risk Does Not Justify Enjoining State In Personam Suits Under the Anti-Injunction Act’s “In Aid of Jurisdiction” Exception

Date: Jul 11, 2026

Indemnification Risk Does Not Justify Enjoining State In Personam Suits Under the Anti-Injunction Act’s “In Aid of Jurisdiction” Exception 1. Introduction Out v. Calamari (captioned in the opinion as...

Enforceable 9.99% “Blockers” Defeat Section 16(b) Short-Swing Liability Absent Plausible Allegations of Sham, Waivability-in-Sole-Discretion, or Real-World Cap Breach

Date: Jul 8, 2026

Enforceable 9.99% “Blockers” Defeat Section 16(b) Short-Swing Liability Absent Plausible Allegations of Sham, Waivability-in-Sole-Discretion, or Real-World Cap Breach 1. Introduction In...

Broad “Remedial Authority” Clauses Permit Compensatory Monetary Awards for Staffing-Grid Breaches Absent an Express Contractual Limitation

Date: Jul 8, 2026

Broad “Remedial Authority” Clauses Permit Compensatory Monetary Awards for Staffing-Grid Breaches Absent an Express Contractual Limitation I. Introduction The New York and Presbyterian Hospital v....

Silence Is Forfeiture (Not Waiver): “Cooperate With and Abide by All Instructions of Immigration Authorities” Supervised-Release Condition Upheld

Date: Jul 8, 2026

Silence Is Forfeiture (Not Waiver): “Cooperate With and Abide by All Instructions of Immigration Authorities” Supervised-Release Condition Upheld I. Introduction In United States v. Salvador (2d Cir....

Conditional Dismissals After Diversionary Programs Are Not “Favorable Terminations” for § 1983 Malicious Prosecution When the Dismissal Reflects a Compromise

Date: Jul 4, 2026

Conditional Dismissals After Diversionary Programs Are Not “Favorable Terminations” for § 1983 Malicious Prosecution When the Dismissal Reflects a Compromise 1. Introduction Chapdelaine v. Desjardin...

Article III Adversity Bars Facial § 1983 Challenges Against State Judges Acting as Neutral Firearms-Licensing Adjudicators

Date: Jul 2, 2026

Article III Adversity Bars Facial § 1983 Challenges Against State Judges Acting as Neutral Firearms-Licensing Adjudicators 1. Introduction Kellogg v. Nichols arises from New York’s handgun licensing...

EPCA Does Not Expressly Preempt State and Local Building-Electrification Measures that Ban Fossil-Fuel Appliances

Date: Jul 2, 2026

EPCA Does Not Expressly Preempt State and Local Building-Electrification Measures that Ban Fossil-Fuel Appliances Case: N of Contracting Plumbers v. City of New York; Mulhern Gas Co., Inc. v. Mosley...

Post-Mahmoud Limits on Yoder: School Vaccination Mandates Do Not Trigger “Same-Character” Parental Free-Exercise Strict Scrutiny

Date: Jul 2, 2026

Post-Mahmoud Limits on Yoder: School Vaccination Mandates Do Not Trigger “Same-Character” Parental Free-Exercise Strict Scrutiny I. Introduction Miller v. McDonald (2d Cir. June 30, 2026) addresses...

CDP Verification Must Include § 6751(b)(1) Supervisory Approval—Even After Prior Liability Adjudication

Date: Jul 2, 2026

CDP Verification Must Include § 6751(b)(1) Supervisory Approval—Even After Prior Liability Adjudication Case: Besicorp v. Commissioner of Internal Revenue (consolidated appeals) Court: U.S. Court of...

Huey v. Anavex: Heightened Plausibility for Delayed, Market-Correlated Losses After a “Corrective” Disclosure

Date: Jun 27, 2026

Huey v. Anavex: Heightened Plausibility for Delayed, Market-Correlated Losses After a “Corrective” Disclosure I. Introduction In Huey v. Anavex Life Sciences Corporation (2d Cir. June 26, 2026), the...

Second Circuit: § 1201(a)(1) “Death Results” Requires But-For Causation, Not Proximate Cause

Date: Jun 25, 2026

Second Circuit: 18 U.S.C. § 1201(a)(1) “Death Results” Requires But-For Causation, Not Proximate Cause 1. Introduction In United States v. Parks (2d Cir. June 24, 2026), Edward Michael Parks appealed...

“Death Results” in Federal Kidnapping Requires Only But‑For Causation, Not Proximate Cause

Date: Jun 23, 2026

“Death Results” in Federal Kidnapping Requires Only But‑For Causation, Not Proximate Cause Introduction In United States v. Parks (2d Cir. June 22, 2026), Edward Michael Parks appealed convictions...

Monell Liability and Qualified Immunity Turn on Disputed “Emergency” Facts in Municipal Demolitions

Date: Jun 22, 2026

Monell Liability and Qualified Immunity Turn on Disputed “Emergency” Facts in Municipal Demolitions Case: Levin, Vodka Properties LLC v. City of Buffalo (2d Cir. June 18, 2026) Court: United States...

Belated § 3731 Certification May Be Cured by Ratification and Attorney General Certification Without Defeating Appellate Jurisdiction

Date: Jun 17, 2026

Belated § 3731 Certification May Be Cured by Ratification and Attorney General Certification Without Defeating Appellate Jurisdiction 1. Introduction In United States v. Robinson (2d Cir. June 16,...

FDCPA § 3004(b)(2) Creates a Mandatory Debtor-Requested Transfer and Its Denial Requires Vacatur (No Harmless-Error Review)

Date: Jun 17, 2026

FDCPA § 3004(b)(2) Creates a Mandatory Debtor-Requested Transfer and Its Denial Requires Vacatur (No Harmless-Error Review) Case: United States v. Liounis (2d Cir. June 15, 2026) | Court: Court of...

Intent to Repay Does Not Negate Federal Fraud: Temporary Deprivation Completes the Offense and Post-Hoc Asset Value Is Irrelevant

Date: Jun 15, 2026

Intent to Repay Does Not Negate Federal Fraud: Temporary Deprivation Completes the Offense and Post-Hoc Asset Value Is Irrelevant Introduction In U.S. v. Bankman-Fried, the United States Court of...

Rule G Standing Hearings: Preponderance Fact-Finding and “Bare Title” Insufficiency for Straw Owners

Date: Jun 3, 2026

Rule G Standing Hearings: Preponderance Fact-Finding and “Bare Title” Insufficiency for Straw Owners 1. Introduction United States v. the M/Y Amadea is a Second Circuit civil forfeiture decision...

Unsettled § 3146(b)(2) Consecutive-Sentence Requirement for Failure to Appear at Supervised-Release Revocation Hearings (No Plain Error)

Date: Jun 3, 2026

Unsettled § 3146(b)(2) Consecutive-Sentence Requirement for Failure to Appear at Supervised-Release Revocation Hearings (No Plain Error) Case: United States v. Simmons, Nos. 23-7400-cr (Lead),...

Federal Diversity Courts Apply New York Anti-SLAPP’s Actual-Malice Standard; CPLR 302(a)(1) Does Not Reach Out-of-State Journalists Absent New York Newsgathering

Date: Jun 1, 2026

Federal Diversity Courts Apply New York Anti-SLAPP’s Actual-Malice Standard; CPLR 302(a)(1) Does Not Reach Out-of-State Journalists Absent New York Newsgathering 1. Introduction The Satanic Temple,...